IR 05000293/1992024

Insp Rept 50-293/92-24 on Stated Date.No Safety Concerns or Violations Noted.Major Areas Inspected:Audits & Surveillances,Collective Personnel Exposure Status,Outage Radiological Controls & Implementation of Exposure Programs

ML20125C152
Person / Time
Site:	Pilgrim
Issue date:	11/23/1992
From:	Mann D, Noggle J, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20125C143	List: IR 05000293/1992024 ML20125C141
References
50-293-92-24, NUDOCS 9212110072
Download: ML20125C152 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /92-24 Docket N License N DPR-63 Lit.nsee: Boston Edison Company RFD #1 Rocky Hill Road flymouth. Massachusetts 02MQ Facility Name: Pilgrim Nuclear Power Station Inspection At: Plymouth. Massachusetts Inspection Conducted: November 2 - 6.1992 Inspector: r Ndf/fz-D. Mann, Radiation Specialist Date Facilities Radiation Protection Section ,

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J. 6aggle, IVdiation Specialist D' ate '

Facilities Radiation Protection Section f N /

Approved by: /[ / d Cf // ~ 2.f- 7C-TV. PaslTak," Chief, Facilities Date Radiation Protection Section Areas Inspected: Areas covered in this inspection included a review of: audits and surveillances, collective persannel exposure status, outage radi, logical contrcls, and the implementation of the internal and external exposure radiological programs curing mid-cycle outage condition Relulu: The licensee has demonstrated a very good performance in the areas inspecte Weaknesses were identiGed in posting of the spent fuel pool to warn against the inadvertent withdrawl of accessible high radiation sources stored in the pool, in staffing of the maintenance ALARA planning section, and in following procedures for issuing Radiation Work Permits (RWPs). Within the scope of this inspection, other than the weaknesses identified above, no safety concerns or violations of regulatory requirements were identifie o072 921123 PDR 0 ADOCK 05000293 PDR-

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l DETAILS [

. Persons Contacted l Lk131on Edison Company  ;

• E. Boulette, Vice President / Station Director A. Bowens, Supervisor Dosimetry W. Caithness, Supervisor Radiological Operations hi. Christopher, Supervisor Radiological Operations P. Drazek, Radiological Protection Technician

• N. Desmond, Compliance Division' hianager B. Eldredge, Quality Control Surveillance Inspector  ;

• F. Famulori, Quality Assurance Division hianager

• R. Gay, Compliance Engineer G. Gordon, ALARA Planning Specialist

• R. Grammont, hiaintenance Section hianager hi. Hollander, Lead HP Technician, Condenser Bay a * E. Kraft, Plant hianager l S. Landahl, Radiological Operations Support Division hianager J. hicClellan, Quality Control Surveillance Inspector F. hiunroe, Supervisor Dosimetry Records K. Norman, Radiological Protection Technician

• 11. Oheim, Regulatory Affairs hianager B. Olson, Supervisor Radiological Instruments  ;

R. O'Neill, Technical Prograr Supervisor J. Posselt, Senior Alara Engineer

• W. Rothert, Director, Nuc!:ar Engineering E. Sanchez, Senior Radiological Engineer L. Sasser, Senior Radiological Protection Technician

• L. Schmeling, Nuclear Services Department hianager T. Tetzloff, Supervisor Radiological Operations D. Twomey, Lead HP Technician,51 Ft Control Point a'

B. Vazquez, Lead Radiological Engineer

• L. Wetherell, Radiological Section hianager A. Williams, Radwaste Division hianager J. Wudyka, Supervisor Respiratory Protection

, NRC Personnel

• J. hiacDonald, Senior Resident Inspector W. Pasciak, Chief, Facilities Radiation Protection Section

• Denotes attendance at the exit interview on November 6,1992,

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2.0 EmPm This inspection was an unannounced safety inspection of the Pilgrim Nuclear Power Station radiation control programs during a mid-cycle maintenance outag I 3.0 Erg _ylpusly identined items (Closed) Inspector Followup Item (92-11-02): Powdered resin samples were not

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dewatered prior to analysi The inspector reviewed a licensee memorandum dated September 15,1992 from Goddard to N. Desmond which provided an evaluation of sample results taken before and ,

after dewatering of powdered resins. The evaluation determined that dewatering of-samples was not necessary to obtain accurate results. Nevertheless, the appropriate' ,

sample and analysis procedures will be changed so that future resin samples will be dewatered to moro closely resemble the final waste form for burial. The licensee has t committed to re using the applicable procedures by December 30,1992. This issue is close .0 ALARA Status The licensee had an annual station personnel exposure goal of 298 person-rem for 1992, which included a four-week mid-cycle maintenance e age estimated to cost 79 person-rem. With eight weeks remaining in the year and approximately one-third of the way through the mid-cycle outage, the licensee has accrued 124.4 person rem during routine operations and 48.5 person-rem during the mid-cycle outage for a total of 173 person-rem to dat The licensee set an annual goal of not more thr.n 90 personnel contamination incidents as compared to a current record of 79 personnel contaminations reported for the yea Standard drywell shielding packages were developed and implemented during this maintenance outage which helped reduce the general drywell dose rates. Other specific job shielding efforts were marginally effectiv Job specific ALARA efforts were provided by two ALARA specialists reporting to the planning office of the maintenance section. These ALARA specialists provide the review of Mi Maintenance Requests. Included in this review they determine those that will require RWPs, they write the initial portion of the RWPs and complete the ALARA checklists, and develop ALARA shield designs. In addition, they instruct station services personnel in the shielding requirements and evaluate the final ALARA shield installation, .

The two ALARA specialist normally are provided with between one_ and three HP I technicians to assist in the completion of these specified work dutie The inspector reviewed the drywell In-Service Inspection (ISI) weld examination work

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locations. The inspector noted that the RWP review and the ALARA review did not require any shielding for ISI weld examinations of the N6B penetration piping although

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survey maps indicated general dose rates of 600 mR/hr with contact dose rates of 2 R/hr ,

in the work area. Only 2 person-rem was estimated for this job. As a result, HP had l determined that shielding was not required. The maintenance section ALARA group had  !

planned for shielding the N6B piping and a drum of lead shielding had been delivered to the drywell entry lay-down area for this purpose. The controlling drywell HP technicians were unaware of the shielding requirement for this work area and were uninformed of the licensee's intention to shield this area before allowing work to commence. This was a communication breakdcwn and the licensee agreed to ensure that shielding requirement documentation is provided to the responsible work area HP technicians. The initial shielding planning was not too effective in this case as following the placement of shield material on the N6B pipe location, high radiation dose rates still persiste The inspector reviewed work associated with the Reactor Water Clean-Up (RWCU) heat exchangers. The RWCU heat exchanger area had been shielded and signed-off allowing work to commence although the shielding was insufRcient and according to the licensee, the general area dose rates were not significantly reduced as a result of the shield installation. The shield design plans were not documented but were orally transmitted to the station s 'ces workers by a maintenance ALARA Specialist, calling for two layers of 3/16 ack lead blankets over fourteen feet of_ the regenerative and non-regenerative heat exchangers lengths. The final shield consisted of one-layer of lead blankets distributed over approximately five feet of the heat exchangers. In this particular case, exposure was wasted in installing the shielding blankets since the final dose rates were not substantially affected. Through discussions with the ALARA -

Specialists, it appears a breakdown in communication and effective shield installation followup were the cause .0 Audits and Surveillanqn I

The licensee had just recently completed an audit of the radiation controls program which had not yet been reviewed by licensee's management chain, and as a result, was not

, reviewed during this inspection. The inspector reviewed 26 HP surveillance reports ,

l which were issued during 1992. There were a number of surveillances conducted over l a wide breadth of subjects indicating an appropriate level of quality control oversight was provided. Deficiencies in work supervisors fulfilling RWP responsibilities, and the lack of radioactive material area storage inventories were reported. The surveillance findings were reported as Deficiency Reports (DRs) which were appropriately tracked. At the time of the inspection the radioactive material area storage inventories issue had been

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adequately dispositioned, but the work supervisor RWP issue had not yet been completely addressed and will be reviewed in a later inspectio . . _ . . ~_ _ .. _ __ _ _ _ _ . _ - . _ _ - _ _ _ ~ _

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5 Qulage HP Operations During this scheduled mid-cycle maintenance outage, the normal HP staff was complimented with 32 contract HP technicians to provide three satellite HP control points -

located in the turbine building condenser bay, at the drywell entry, and on the reactor building 51 foot elevation. The inspector reviewed all of the major work locations, radiological surveys, RWPs, and log book records at each of these control points. In general, the work areas did net contain radiological postings including dose rate postings 1 or hot spot warnings. One area in the turbine building condenser Day was an exception to this. The licensee depends almost exclusively on the review of surveys and pre-job i briefings of the workers to communicate the work area radiological information. Por the work evolutions witnessed during this inspection, the licensee provided appropriate HP job coverage and no discrepancies were noted. Surveys were also found to be routinely performed and of good qualit .

The inspector ated an area of concern involving a few RWPs that were issued improperly according to station procedure. The licensee has a well written RWP procedure entitled " Issue, Use, and Termination of Radiation Work Permits",6.1-022, Rev. 31. Section 8.5, requires the HP technician to obtain work area radiological survey -

information and enter the pertinent informadon on the RWP. The HP technicians are instructed to ensure that the radiological survey information is the most recent and reflects the current conditions in the work area. Roughly 5 - 10% of the active RWP's

, had been issued with either outdated information in the radiological conditions section of the RWP, or v>ith no information at all. The licensee assured the inspector that actual surveys were performed and further, that the workers were briefed using the current survey information (survey sheets) and not the radiological conditions as specified on the RWPs. The worker is required to sign the RWP sign-in sheet which specines that the ,

worker has read, understands, and will comply with the RWP and has reviewed the current radiological survey sheets for the RWP. Apparently a number of RWPs were written and issued before actual work condition radiological surveys had been performed -

and although current radiological surveys had subsequently been performed, the RWPs still listed incorrect radiological information. The licensee agreed to provide greater -

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attention to this area to ensure that the RWPs are issued with accurate radiological condition informatio While touring the refueling Door, the inspector noted a number of- ropes tied to the

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railing around the spent fuel pool which were attached to submerged high radiation reactor hardware components. The area immediately around'the pool was posted as a hot particle exclusion zone, however there were no postings or barricades to warn or prevent workers in the area- from pulling up the ropes and causing an unintentional exposure situation. The licensee indicated that workers are instructed _during.RWP >

brienngs not to pull up any of the ropes without proper radiological controls. The lack i_ of visible postings associated with the tied off high radiation sources is considered a

, weakness in light of the potential safety signincance of the unintentional withdrawl of one of these high radiation sources. The licensee did correct the posting denciency by placing signs around the spent fuel pool area which state,"Do not handle any ropes or

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pull any material up from the fuel pool without RPhi permission". Lniernal n Exoosure Control The inspector reviewed the respiratory protection equipment issue and control progra The licensee maintains a central issue location for respirators. The station issues, through dosimetry records, a respirator ID card to those individuals who have completed the requirements for wearing a respirator. The dosimetry clerks verify that the individual requesting a respirator ID card has the required qualification to wear the device. These qualincations include: a current whole body count, up-to-date training in respiratory protection, a valid fit-test, and a current physical examination certifying eligibility. The ,

Radiation Protection (RP) technician issuing the respirator takes possession of the ID card

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in exchange for the respirator. The individual may then perform work while wearing the respirator. After completing the work, the individual returns the "used" respirator and receives the ID card in exchang .

The licensee's respiratory protection fit-test program utilizes the PortaCount-Plus system instead of the traditional corn-oil booth. The calibration and cleaning of this equipment i s performed annually by the manufacturer. The liceesee performs a daily quality control

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zero check usmg a HEPA filter. The licensee performs fit-testing using appropriate procedures in accordance with the ANSI /ANS Z88.2-198 '

The licensee maintains a whole body counter (WBC) that utilizes two stacked sodium iodide (Nal) detectors to perform one minute bioassay counts. The licensee's qualit assurance program for the WBC includes a daily count using a "'Cs/"Co check sourc The result of this couat is plotted on appropriate control charts to determine that the

results are within three standard deviations (13o) of the mean in addition, the licensee participates in a quarterly " blind" cross check sample program. WBCs of personnel are considered to be valid if *K is identified and no unidentified peaks are identined. in addition, a count is considered valid if the minimum detectable activities determined by the computer for isotopes that are not present are less than that activity which

corresponds to 10 h1PC-hrs.

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The inspector reviewed the air sample counting equipment and associated procedure The licensee uses a Geiger-hiuller (Ght) tube detector for gross beta,-a scintillation

detector for gross alpha determinations, and a gamma spectroscopy system for isotopic determinations. A daily source check, a background determination, and a minimum-i detectable activity (h_IDA) determination are required by procedure for these counter The results of the daily source checks are plotted on appropriate control charts. A source check result that is greater than 13a from the mean requires the instrument to be

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removed from service for repair. The gamma spectroscopy system is involved in the

quarterly " blind" cross check sample program which is analogous to the WBC program.

l The inspector noted that the licensee's QC program for these instruments did not outline-any requirement for review of the check source (control chart) data, in addition the

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program did not include any specinc criteria for increased review or corrective action based on the results of the daily source check. The licensee indicated that the analytical r

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instrument and whole body counting QC programs would be reviewe The inspector reviewed the MPC-hour tracking program and noted that the licensee begins tracking at 0.1 MPC-hrs. The primary method of determining exposure to

, airborne radionuclides is by air sample analysis. However, the licensee's program includes appropriate feedback to the MPC-hr tracking system for non-routine in-vivo (whole body counting) measurements. No violations associated with the internal l exposure control program were ic ntifie : External Exposure Contml

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The inspector reviewed the licensee's programs for multiple _ whole body do_simetry and

cxtremity dosimetry monitoring. The licensee's progran requires multiple whole body dosimetry when the exposure rates exceed 100 mR/hr, the exposure rates differ between the chest and any other locatioa on the whole body by greater than 2 times, and the total dose that the worker is expected to receive exceeds 300 mrem. The licensee's program requires extremity dosimetry when the exposure raie at an extremity exceeds 4 times the !

exposure rate at the chest and the total dose that the worker's extremity is expected to receive exceeds 40() mre These criteria fall within regulatory monitoring -

requirements. No discrepancies were noted.

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The inspector also reviewed the dose convers;on factors used by the licensee to calculate personnel exposures. These factors were based on the assumption that the contaminating l isotopes were 'Co and '"Cs in a 75/25 ratio. A monthly analysis is performed to

reverify the validity of the isotopic mixture assumption. The inspector reviewed the

, licensee's technical basis document which is the basis for the skin dose calculation coefficients. The inspector noted that the technical basis document was very well don The inspector reviewed the liccasee's program for issuing and controlling survey instruments. The licensee performs a daily source check to verify tha: the instrument responds appropriately (120%) for at least one point on each of the readout scales. The licensee allows qualined individuals to self-issue survey instruments. Information in the instrument issue log book include.s cunent calibration information and daily check source dat The inspector reviewed selected log book entrie., and did not find an discrepancies. In addition, the inspector reviewed the qu/.;ty assurance department audit of the instrument issue progs.im and noted that the audit of the log book entries did not result in any finding The licensee implemented some changes to the personnel monitoring program on July 1,-

1992. The inspector reviewed the technical basis document written by the lic:nsee

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supporting the changes. The revised monitoring program removed the licensee's self-imposed requirement to provide everyone who entered the protected area -with a L thermoluminescent dosimeter (TLD). To change this self-imposed requirement the

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i licensee had to classify individuals who were " required" by regulation to be monitored as radiation workers. The licensee classified the workers using the monitoring criteria in the proposed 10 CFR 20 (new Part 20), since the new Part 20 requirements are more

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limiting. Individuals who are restricted from entering contaminated areas, airborne radioactivity areas, and high radiation areas are no longer required to wear a TLD and i

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are not required to receive annual whole body counts or physical examinations. Visitors are included in this category. An individual may enter a radiologically controlled area (RCA) without a TLD; however, they are required to wear direct reading dosimetry and - l their exposure is administratively limited to 25 mrem / quarter. The licensee addressed some potential problem areas and provided solutions to them. These problems included i

issues such as: dose accountability for an individual who changes monitoring categories within a quarter, or visually distinguishing between individuals required to wear a TLD i from individuals not required to wear a TLD. All declared pregnant females are issued j a TLD regardless of the monitoring category. Individuals who enter the protected area for the first time after July 1,1992 will not receive a termination letter when they leave the site. Individuals who were monitoied previously, but under the revised categorization are no longer monitored, received a letter providing them with a record of their weapational dose for the entire period during which they were monitored. No violations re identified relative to the licensee's external exposure monitoring progr:un .

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9.0 Exit Meeting The inspector met with licensee representatives at the conclusion of the inspection on  !

November 6,1992. The inspector reviewed the purpose and scope of the inspection and discussed the fmdings.

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